Electronic Filing Of Transfer Agent Forms - Securities And Exchange Commission Page 23

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Commission is the ARA file Form TA-1 and Form TA-W with the Commission; however, all
registered transfer agents, whether they are registered with the Commission or another ARA, must
file the annual Form TA-2 with the Commission. Compliance with the proposed amendments would
be mandatory. The information required by the proposed amendments would not be kept
confidential by the Commission. The Commission's regulations that implement Section 17A of the
Act are at 17 CFR 200.80 et seq.
The amendments modify an existing collection of information by changing the format of a
required filing from paper to electronic format and modify the text of the forms and the instructions
to the forms to conform to the electronic filing requirement.
The Commission does not estimate that the hour burdens for Form TA-1, Form TA-2, and
Form TA-W will change as a result of the proposed amendments because completing an electronic
form template and submitting it electronically on EDGAR should not take longer than completing a
paper form and mailing the original and two copies to the Commission. The Commission believes,
however, that the estimated hour burdens of Form TA-1 and for Form TA-2 should be increased for
the first year to reflect the initial burden associated with filing electronically on EDGAR and the
initial burden associated with the proposed requirement for each transfer agent registered with the
Commission to refile the information on its Form TA-1 electronically as an amended Form TA-1.
We estimate that the one time burden associated with electronic filing of transfer agent forms is two
hours. This increased burden would be incurred with respect to the first transfer agent form the
transfer agent files with the Commission electronically. For transfer agents registered with the
Commission, this would be Form TA-1, because the proposal would require transfer agents
registered with the Commission to file an electronic amended Form TA-1 before they could file any
other transfer agent forms electronically. For all other transfer agents, this would be Form TA-2
because that is the only form those transfer agents file with the Commission.
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